Federal Aviation Administration U.S. Department of Transportation (DOT) Docket Operations, M-30
1200 New Jersey Avenue SE, Room W12-140, West Building Ground Floor Washington, DC 20590-0001
Re: Docket No.: FAA-2023-0855
Request for Comments on the Federal Aviation Administration's Review of the Civil Aviation Noise Policy
The City of Pacifica (the "City") welcomes the opportunity to comment upon the consequential noise burdens that are imposed on our residents, visitors and businesses by departing flights from San Francisco International Airport. As the current FAA noise policy dates from 1976, it is certainly time for its update.
The City of Pacifica is a community of approximately 38,000 residents, businesses and hotels spread along a 6-mile stretch of coastal beaches just south of San Francisco, approximately 5 miles from the San Francisco International Airport. Topographically, the City is comprised of several steep hillsides and valleys leveling off to the Pacific Ocean in the west. We have significant open space that is the key economic driver for us - people come to Pacifica to hike, surf, ride horses and bike in quiet, natural surroundings.
We are an “overflight community” based on FAA’s definition as we are located under the flight paths of aircraft and vehicles, are distressed by aircraft noise, and are located outside of the DNL 65 dB contour. Aircraft must rise quickly leaving SFO to clear our mountains but are often still flying at or below 3,000 feet as they enter our community, flying directly over homes. This is despite years of lobbying for flights to fly out high and well over the Bay or over water, so they are not heard by our residents.
Per the May 2023 monthly report from the SFO Noise Office, Pacifica currently gets 196 noise events/day (time and duration methodology) and 235 noise events/day (using the new and more accurate ANEEM methodology below). Pacifica has 61 CNEL (time and duration), and 62 CNEL (ANEEM). Our SEL and LMax are 84 and 73 (similar in both methodologies). Our Ambient level noise is only 59 dBA, so these events are a large deviation from our normally quiet environment.
We have been greatly impacted by NextGen policies that started in approximately 2016. NextGen drastically increased low-altitude aircraft concentration over communities and changed where and how aircraft fly. Prior to NextGen, noise primarily affected parts of our northern area. After NextGen the noise in this area worsened. Additionally, changes were made to the flight paths so that the entire eastern ridge of Pacifica started being affected as turns to the west now travel over our southern area. Additionally the topography of our community (low-lying areas, surrounded by steep hills) means that any large sounds tend to reverberate far beyond their direct path.
Residents were appalled and calls about painful noise spiked despite assurances NextGen would mean quieter skies for our area.
While we welcome recent changes to aircraft procedures through the SFO NIITE and HUSSH programs adopted in 2022 that allow some aircraft departing southward along specific runways to use an alternate route over water at the San Francisco Bay before turning over the Golden Gate Bridge from 1-5am, there are still significant flights over Pacifica all hours of the day and night. These runways are too short for larger passenger and cargo planes, cannot be used in certain wind or weather conditions, and are not used for flights to Asia, which make up a significant portion of flights over our community starting around 11pm. Procedural changes for departing flights should be considered to reduce the noise, health and annoyance impacts to our community, including:
A. Consideration of a nighttime curfew
B. Incentivising or requiring airlines operating at night to use quieter aircraft and takeoff techniques.
C. Expanding NIITE and HUSSH programs to more accurately reflect critical sleep hours from 10-7
D. Requiring all departures from runway 28 L and R to turn right over the bay immediately after takeoff. If the aircraft is unable to make this maneuver safely, then the departure flight time should be changed to a non-curfew hour between 8am and 9pm only or move to Oakland’s main runway which departs over the bay and has no back blast into communities.
E. If this is not possible, then at a minimum, requiring departures from Runway 28 to fly straight over the ocean for 5 miles before turning to limit the impacts.
The FAA's current 65 DNL metric for assessing "significant" noise fails to account for the realworld, notable noise burdens created by multiple, continuous, moderate-level dB jet noise events.
In addition, this is an unceasing disturbance in areas that are not contiguous to any airports, yet current metrics find this noise not to be "significant." NES established an up-to-date survey of annoyance, proving that many more people are annoyed by aircraft noise at DNL levels far below DNL 65 dB. Studies have shown that irregular, unpredictable noises make it difficult for our brains to wholly focus, interrupting concentration on work/school tasks or waking people from sleep. And, although numerous moderate-level noise events don’t contribute a lot to total decibel levels on the FAA’s DNL scale, they are seen as some of the most irritating to the human brain. To describe these health consequences as “annoyance” is a misrepresentation of the real and cumulative effects on our community.
We very much appreciate the FAA’s consideration of research into the health effects of aircraft noise and request that noise be considered as an operational factor equal with efficiency, just behind safety, in determining future policies and procedures. Aircraft noise at night, which repeatedly prevents or disturbs sleep has been shown to have long-term cognitive and cardiovascular health issues and can interfere with learning in children at critical stages of development.
Our comments are detailed below. Note that we have not chosen to answer every question.
Section 1 - Vehicle Type
QUESTION 1A
When the FAA published the ANAP (27) in 1976, the impacts of aviation noise were related to commercial jet service at or in the immediate vicinity of airports. What types or elements of current or future air vehicle activity (e.g., unmanned aircraft systems (also known as UAS or drones), advanced air mobility, rotorcraft, subsonic fixed wing, supersonic, or commercial space) should the policy describe and disclose? How should this information be described using noise metrics? Should the FAA use this information to make decisions or for public disclosure only? Please explain your reasoning.
Supersonic Aircraft
We oppose supersonic flight over the land of the United States and the US Territorial Sea (12NM offshore) regardless of any purported “quiet sonic boom” technology.
Helicopters
We value the services provided by medical, law enforcement, and military helicopters and recognize the necessity of low-altitude helicopter operations for items such as special inspections, repairs, and photo reconnaissance. Helicopters as a regular transportation method for convenience or tourism should be regulated by the FAA considering minimum altitudes and bans for nighttime use.
Emerging Aircraft
Low altitude autonomous aircraft, whether designed to act as “air taxis” (eVTOLs) or to deliver packages, should be strictly regulated in conjunction with local elected officials and the public in the areas that they traverse.
Section 2 - Operation of Vehicles
QUESTION 2A
What elements of aircraft operations (e.g., en-route, takeoff, landing) should the noise metric evaluate and disclose? Should the FAA use this information to make decisions or disclose to the public noise impacts? Please explain your reasoning.
Noise impacts of aircraft operations should be disclosed for ground-based noise at the airport, as well as en-route, takeoff and landing. These operations impact communities differently, and it is important to evaluate and disclose the data and impacts to the public. This data beyond the simple DNL metric may find nuances that can be addressed by local communities working in partnership with the local airport noise offices. For Pacifica we are mostly affected by low-flying aircraft over our hills shortly after takeoff.
QUESTION 2B
What interests or concerns do communities in the vicinity of airports have? How can these concerns be addressed using noise metrics? What noise metrics would address these concerns? Please explain your reasoning.
Our main concerns are related to the operations of air vehicles, including night operations and non-safety vectoring for efficiency of aircraft from published procedures and/or noise abatement procedures. Due to the limited altitudes possible over our community after takeoff (approximately 3,000 feet), the noise impacts are great, especially over the departure path known as the "Gap", over our northern mountains. When planes turn early instead of over the ocean, they also impact other quiet residential neighborhoods in our valleys, where the noise reverberates. There are also occasions when controllers offer or approve shortcuts to airplanes – allowing the planes to leave their filed flight plan path to fly over residential areas in the middle of the night for efficiency reasons with virtually no other traffic in the sky. In these instances, ATC controllers should prioritize health over efficiency and avoid non-safety vectors to aircraft over residential areas - especially at night. Noise metrics that use N-Above Ambient (NAA) for the peak day are more representative than DNL for Overflight Communities such as ours.
QUESTION 2C
What interests or concerns do overflight communities (28) have? How can these concerns be addressed using noise metrics? What noise metrics would address these concerns? Please explain your reasoning.
NAA metrics better represent overflight communities such as ours. NAA is the counting of noise events with a peak noise level Lmax (with applicable and revised nighttime penalties) that exceeds ambient noise. It is calculated based on ambient noise, which is the typical background noise level without air vehicle noise, for the peak day of the year, reflecting the fact that noise events that exceed ambient noise will disturb people. Note that the Federal Railroad Administration and the Federal Highway Administration take into account ambient noise when assessing impacts. NAA also better reflects the greater impact on our community at various times of the year due to wind/storms/etc. where alternate runways and departure procedures are used.
These more accurate noise metrics with NAA may also expand the areas of needed sound insulation improvements beyond the limited 65DNL contour, which would be a great help to our residents.
Section 3 - DNL
QUESTION 3A
What views or comments do you have about the FAA’s core decision-making metric, DNL? How would these views regarding DNL be resolved if the FAA employed another noise metric (either in addition to, or to replace DNL) or if the FAA calculated DNL differently? Please explain your reasoning.
Impact to our community extends far beyond an arbitrary DNL 65 level which is widely acknowledged to be inadequate. There are other available noise metrics, including those that better capture how frequency of flights affects communities. Living in 60 DNL or 55 DNL noise contours, especially if the area also includes loud nighttime airplanes, limits residents’ amount of health-restoring sleep, increases their susceptibility to serious disease and results in very high levels of annoyance. In 1974, the Environmental Protection Agency (EPA) recognized the importance of setting a low level of 55 DNL but that recommendation by the EPA was not accepted by the FAA. It should be reconsidered now with the new data about health impacts of noise.
In a recent study conducted by Boston University School of Public Health (BUSPH) and Oregon State University, (https://ehp.niehs.nih.gov/doi/10.1289/EHP10959) it was reported that people who were exposed to airplane noise at levels as low as 45 dB were more likely to sleep less than 7 hours per night. Other studies have correlated awakenings with Sound Exposure Level (SEL).
SEL may be an appropriate single-event noise metric to use as the onset of awakenings from aircraft operations at night depending on the level of treatment applied to the structure; and be used to determine the acoustical treatments required to provide for an adequate sleeping environment for residential bedrooms. However, understanding that SEL and Lmax are closely tied with the noise events caused by aircraft operations, either metric could be used.
Section 4 - Averaging
QUESTION 4A
DNL provides a cumulative description of the noise events expected to occur over the course of an entire year averaged into a representative day, described as an Average Annual Day (AAD). a. Do you believe an AAD is an appropriate way to describe noise impacts? Please explain why or why not.
No, averages do not tell the full story of event disturbance, particularly day versus night, weather related path changes, or frequency of events. Perhaps DNL is adequate for certain communities near the airport in the 65 DNL contour, but Overflight Communities need different metrics.
Section 5 - Decision-Making Noise Metrics
QUESTION 5A
The FAA currently uses DNL as its primary decision-making metric for actions subject to NEPA and airport noise compatibility planning studies prepared pursuant to 14 CFR part 150. a. Should different noise metrics be used in different circumstances for decision-making? Yes. The concerns of communities near the airport are different than departures for overflight communities and a one-size-fits-all metric does not fully describe the impacts to these communities. Also, DNL does not work well away from the airport, either for departures or arrivals.
QUESTION 5B
If the answer to Question 5.a. is “yes,” please identify: the metric, the information it provides that DNL does not, and explain when and how it should be employed by the FAA in its system (e.g., should the FAA use a noise metric other than DNL to evaluate noise exposure in quiet settings, such as national parks, national wildlife and waterfowl refuges, etc.)? Should this metric be used when the FAA is making decisions that affect noise in these settings? Should this metric be used alone or in combination with another metric?
The FAA should use and report N-Above-Ambient using Lmax for the peak day of the year (which counts the number of aviation noise events over a certain location and decibel level) because (1) the frequency of noise disruptions is highly correlated with annoyance, and DNL (an averaging metric) fails to account for this; (2) the FAA also should consider using and reporting a C-weighted metric (dBC), which measures the lower frequencies of noise that are at the source of most annoyance and sleep disturbances farther from the airport, but which are discounted by the Aweighted metric (dBA) currently in use; and (3) the FAA should also measure and incorporate the differences in aircraft-induced noise and ambient noise levels for determining significant impact thresholds for different noise environments. To improve the true representation of noise impacts, we encourage the FAA to immediately start reporting these additional metrics, not just DNL, if the data is available.
Section 6 - Communication
QUESTION 6A
Please identify whether and how the FAA can improve communication regarding changes in noise exposure (e.g., what information the FAA communicates, where and with whom the FAA communicates, what information methods the FAA uses to communicate and the venues at which the FAA shares this information). Please explain your reasoning.
The issues we have had with NextGen updates show that early communication with and input from affected communities are critical to obtain before policies are finalized, and input should be sought and adjustments considered after new policies have been implemented and tested so communities can understand and provide feedback on the changes.
No one worked with our City or even alerted us that the proposed changes from NextGen would negatively impact our community. Communication to SFORT (San Francisco Airport Community Roundtable) members, including our Council representative at the time, were that NextGen would be less intrusive and positive for the environment. By the time we learned what NextGen’s impacts really would be, it was too late to comment or suggest modifications.
Section 7 - NEPA and Land Use Threshold Established Using DNL or for Another Cumulative Noise Metric
QUESTION 7A
How should the FAA consider this information (i.e., the Schultz Curve and Neighborhood Environmental Survey findings) when deciding whether to retain or modify the FAA noise 31) established using the DNL metric or to establish new FAA noise thresholds using other cumulative noise metrics? Please explain your reasoning.
If metrics are changed to better reflect the actual “annoyance” experienced as noted in the Neighborhood Environmental Program, insulation programs could possibly be expanded. Current DNL of 65 has a very small eligibility. Based on the NES results DNL 65 should be lowered.
QUESTION 7D
In examining whether to change its metrics and thresholds for noise, the FAA needs reliable information to support any changes. One type of information that the FAA can rely on is epidemiological evidence. This means the study (scientific, systematic, and data-driven) of the distribution (frequency, pattern) and determinants (causes, risk factors) of health-related states and events (not just diseases) in specified populations (neighborhood, school, city, state, country, global). What amount of epidemiological evidence is sufficient to provide the FAA with a sound basis for establishing or modifying the FAA noise thresholds (33) either using the DNL metric or another cumulative noise metric? Please explain your response.
Health experts should address the Noise Policy Review health questions. An independent, unbiased, and peer-reviewed consensus report should be commissioned from the National Academies Division of Medicine on aviation impacts on public health.
We also support the comments of the SFORT, Comment ID FAA-2023-0855-1254 and those of the Aviation-Impacted Communities Alliance (AICA), Comment ID FAA-2023-0855-2206. <END OF QUESTIONS/COMMENTS SECTION>
In summary, simplicity in a new noise policy cannot be at the expense of Overflight Communities whose impacts are underrepresented today under current noise policies. We support changes, additions, or replacement of the current noise metrics used by the FAA, or other actions that would accurately reflect and reduce the real-world aircraft noise that adversely affects our residents, schools, visitors and businesses. For emerging technologies and civil rotorcraft and for air traffic flying below 2000 ft., we also request allowing local governments such as ours to establish local noise ordinances.
With our significant areas of open space and the ocean forming our western border, Pacifica is also home to large wildlife populations including several endangered and threatened species.
There seems to be little data about the effects of aircraft noise on wildlife and we would encourage the FAA to support peer-reviewed scientific studies related to these impacts in the future.
Additionally, Pacifica’s economy is strongly tied to these areas of open space and coast, as a well-used recreational oasis for the Bay Area, where individuals can seek the beauty and peacefulness found in nature. We do not have an industrial area to route aircraft over. We learned from the Phoenix Airport lawsuit that NextGen was supposed to protect such areas - parks, open spaces, etc and yet the policies worsened the flight paths and noise impacts over these areas in Pacifica.
We hope, moving forward, the FAA, a body elected to serve the US people, is more proactive in gaining input from communities whose general health, well-being and economy are so impacted by the operations of local airports. Given our proximity to SFO, the City of Pacifica has many residents with expertise relevant to suggesting actionable ideas that could mitigate noise while maintaining the safe and efficient use of our airspace (some have already been shared with City Council) - all we need is to be informed and asked before changes affecting us are made. We appreciate this opportunity to comment, and look forward to continued work with the FAA and the SFO Airport Roundtable.